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To,
market.abuse@fca.org.uk,

Dear Sir/Madam,

I wish to complain about an apparent breach in AIM rule 17. Notification of holdings for RNS No 6667Q. The transaction took place on the 10/6/2020 and notification of holdings was made to the LSE on the 20/6/2020. Acacia had reduced holdings from 10.81% to 8.99% . Such a delay in notification is completely unacceptable and has potentially impacted on trading in 4D stock as I had personally withheld trades in anticipation of holdings and am not sure if we can now expect a further delayed RNS.

I refer to the notification period of four trading days set out by the FCA, D.T.R 5.8.4. For a non uk issuer which I assume, Acacia Research Corporation of Irvine, California, United States of America are....

“The notification to the issuer shall be effected as soon as possible, but not later than four trading days in the case of a non-UKissuer and two trading days in all other cases, after the date on which the relevant person:
(1) learns of the acquisition or disposal or of the possibility of exercising voting rights, or on which, having regard to the circumstances, should have learned of it, regardless of the date on which the acquisition, disposal or possibility of exercising voting rights takes effect; or
(2) is informed about the event mentioned in DTR 5.1.2 R (2).
And for the purposes of (1) above a person shall, in relation to a transaction to which he is a party or which he has instructed, be deemed to have knowledge of the acquisition, disposal or possibility to exercise voting rights no later than two trading days following the transaction in question and where a transaction is conditional upon the approval by public authorities of the transaction or on a future uncertain event the occurrence of which is outside the control of the parties to the agreement, the parties are deemed to have knowledge of the acquisition, disposal or possibility of exercising voting rights only when the relevant approvals are obtained or when the event happens.”

https://www.handbook.fca.org.uk/handbook/DTR/5/8.html

I wish to raise a formal complaint about this apparent breach. If this complaint is appropriate please can you deal with it according to your procedures and advise.

Thank you in anticipation.

Kindest Regards

Trek.

Ps feel free to cut and paste if you so wish to send a complaint. Personally I think Acacia are taking the pss and they know full well what they are doing!

They have got their cash position sorted with the raise and £4m on the books. Operational expenditure looking like £3.6m this year so they have factored in funds for chemistry and mBC trials.

Surely one of the 4 MOU’s will result in clinical trial or something from the UCL collaboration. The risk here of course is some university finances post Covid, but then they have got a free carry for the Covid trials with Dundee Uni.

Got 6 insti’s with declarable holdings and two directors with decent size holdings. I haven’t been through options and warrants but will if I plan to buy.

Science is compelling and Barry Clare seems confident

“We move forward with the confidence that the value of SFX-01 as a potentially drug that is active against the two key pathways of Nrf2 and STAT3 will become increasingly clear. We therefore believe that the fundamentals are in place to underpin sustainable share price growth and deliver the undoubted potential of SFX-0”

Plenty of short term sp drivers here. Obviously completion of the CMC investment, loads going on MOU/collaboratively wise but obviously not without risk. For me it’s the breast cancer stuff that’s key. Some other projects are developing and they have had one set back, investors will be mindful of that albeit there were benefits.

Outlook, a reasonable assessment...

“We look forward to completing our key toxicology and formulation
work and hopefully the initiation of clinical trials in new indications. We believe that the value of SFX-01 as a potential drug active in each of the Nrf2 and STAT3 pathways will become increasingly clear and the considerable commercial opportunity this represents recognised. We will also continue to explore the opportunities for monetising our assets in non- pharmaceutical markets.”

Add to that perhaps one of the key drivers could be who they appoint as a CEO. Get the right person in someone with a track record of delivering partnership and seeing through clinical trials and that could make a big difference.

I will put this one on my watchlist for no other reason than I am fully invested atm having just added at ONC and 4D. GL.

Trek

Holdings post Ruffer reduction in June 2nd. They have not sold a declarable amount since. Also University of Nottingham probably out now, 29th May. Possibly due to Covid financial impact.

Balderton Capital III, LP……..10.7%
Genostics Company Ltd……..10.1%
Blind Trust (Richard Sharp)…7.0%
Ruffer LLP………………………….. 4.7%
Credit Suisse……………………….4.7%
Mr Timothy Brian Bunting……4.7%
Premier Miton Investors …….3.3%

Add in other directors small holdings that’s around 45% but looks like quite a bit of interest below declarable, 3% UK, 5% international....

“ as at 11th May 2020, 28.6% of the Company’s AIM securities was not in public hands.”

Warrants... “IPF a warrant, exercisable for seven years, to subscribe for 2,036,015 new ordinary shares of £0.01 in the Company at £0.87p” this is for the loan. No others which is encouraging.

Options from 2019 nothing excessive and..

“subject to the rules of their respective plans including vesting in five equal annual parts. Of this total of 101,281: 56,352 share options are exercisable at £1.09, 37,778 share options are exercisable at £1.08 and 7,151 share options are exercisable at £1.26.”

So the warrants are all currently within the share price and fair play to the BoD. Still I think the directors bar R Sharp who added significantly are a bit light though albeit I appreciate not all AIM directors are millionaires.

Looking forward a key driver will be sales from CDT-Lung and CDT-liver.e.g 200k tests is £12m (x costs). 3 year plan will increase scope of tests with Ovarian, Prostrate and breast in next 2months. These should soon be big numbers at all high margin and with existing contracts and unmet need sales should be forthcoming.

Add in the immunoinsights, we have been told 2 more deals to come and you get a picture of a strong developing revenue base.

They may raise for acquisitions or perhaps if there is a revenue lag but then they have credit facilities. Imo any raise should be at a much higher SP. It helps that a couple directors have significant holdings. They have just moved to new labs and have lab capacity as offering Covid diagnostics to Pharma so infrastructure/capacity is ok.

Royalty payments from Roche, undisclosed, plus 3 others & a five-year US$28mln partnership with Biodesix. Don’t loose sight that we have a immunogenic protein library of over 8k antigenic proteins. It’s massive!

Min 8k lung cancers in uk not diagnosed as a result of Covid lag. Amplify that globally and you get the pent up demand. The test cuts due process short.

4% of health care budget is spent on diagnosing cancer and 96% spent on treatments (all referenced)!

Auto antibody treatment is proprietary to ONC! ‘Leading Pharma will pay top dollar for diagnosis’…so ONC are profiling the immune system to identify cancers and responses to treatments. Massive potential!

“Plenty more Roche’s are in the pipeline!” Quote!

Expect Finncap to increase their £1.50 Sp target soon.

Trek

Worth reading the half year report, at least the first 8 pages. It gives a heads up of the expected news flow. Better to read in entirely rather than post highlights. But also note the cv’s of the scientists involved in ONC! Ask yourselves why would they join ONC especially having led key divisions in AZN.

“Prior to joining Oncimmune, Tariq was Chief Physician Scientist, Vice President in the Clinical Discovery Unit AstraZeneca”.

I do think though that some of the BoD should be increasing holdings at these levels.

https://oncimmune.com/wp-content/uploads/2020/02/H1-2019-Interims-Announcement-FOR-APPROVAL12.02.20.pdf

The NICE review for CDT-lung is completed. The highlights are in the 17th March RNS.

Here’s the full NICE review. Note there are several reservations around savings over SOC. These things are always guarded but the direction of flow is very favourable and the product is endorsed with recognised savings over CT only.

https://www.nice.org.uk/advice/mib209/chapter/Summary

This could be the next significant news...

‘At the end of 2019, approximately 500 patients had been recruited of which, 193 had confirmed lung cancer and a further 101 patients with identified IPNs are being monitored for further follow up.

Further results from this study are expected by the middle of calendar year 2020 and will be used to support our application for approval of EarlyCDT Lung with China’s National Medical Products Administration ("NMPA").’

Given the size of the Scottish trial (12209 pts) and that it met end points the Chinese trial should be a slam dunk!

Then there is Russia.... well all of Moscow! Led by R-Pharm

“R-Pharm is expected to focus initially on implementing a screening programme across the c.12m population of Moscow. Russia has 38m smokers, the highest number in Europe..”

The tests cost £600 for a batch of 10, you have to factor in another £10 for processing. So £70 a test not over expensive but that translates into a volume product. From memory 158k tests last year. It’s really not enough.

There are distributors in Brazil, Singapore and Malaysia as well as US, UK, Germany and across Europe. Spain is looking very encouraging. But whilst the geo is impressive we need to see the numbers and/or increase the tests. This is happening.

Also other collaboration and projects ongoing so lots of news to look forward to.

Trek

Trek

Trek

Just noticed this on web page, wasn’t there last time I looked. Not sure on take up though.

COVID-19 Support

Whilst pharmaceutical companies around the world work to develop a vaccine for COVID-19, Oncimmune can provide access to our high throughput antigen arrays during this time, to predict responses to vaccines and therapeutics against the COVID-19 virus.

With our expertise in the immune system and our high-end serological profiling platform, Oncimmune can provide the following to aid the study of the immune response to vaccines and therapeutics aimed at COVID-19:

Customisable immuno-assay panels in a high throughput multiplexed method
Assays for antibody binding to synthetic peptides, vaccines & recombinant proteins
Automated robotic systems for handling large numbers of serum samples
Luminex technology for performing up to 400 immuno-assays in a single 96 plate well
Rapid testing and rapid project turnaround
Semi-quantitative measurement of immunoglobulins (IgG, IgA & IgM) from low volumes of sera (only 1 µl needed to measure 1000 antigens)
Development of CE-IVD ELISA kits for successful candidate antigens.
Our immuno-assays utilise highly validated technology to study the interaction between a set of antigenic proteins or peptides coupled to magnetic beads incubated with the antibodies in a patient sample. Our immune assays require low sample volumes and allow the measurement of hundreds of peptide and protein antigens simultaneously, making this a valuable tool for high-throughput investigation of protein-antibody interactions of multiple targets at once.Our bioinformatics and omics-data analysis platforms support large-scale data mining of assay, patient outcome data for creating machine learning models of outcome prediction.
Possible applications through investigation of:

Patient antibody profiles pre, during and post-treatment, and after recovery from infection

Vaccine response in animals and patients after vaccination

IgG transience in a timed manner after immunisation, data mining support for predictive machine learning based assay panels.

Trek

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